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An wmployer not paying over payroll taxes has much, much greater problems. Payroll withholding is from the employees earnings...it is their money to pay their tax liability. the employer has those funds in trust for the employee ans US Govt. Not paying them is a criminal act of theft, just to start. Also, payroll taxes, as trust funds, pierce the corporate veil...meaning officers and responsible employees are personally liable for the entire amount, and their is no corporate protection. Generally, Each type of tax, (there are zillions of different types, by different jurisdictions), can change the answer a little. In almost all cases, the initial amount of tax is almost unimportant after a while since your still accruing interest, penalty, etc., ...whats the SOL on it? And most importantly, tax liens, generally, don't actually have an SOL. They end once they are paid. If on a property, that will be when the jurisdicition gets paid which may be (and frequently is) when they force a collection by sale of seizure of asset. However, I suspect you may be thinking about what the SOL is for assessment of a tax. A different thing from collecting, but still varies by all the things...which tax, where, how it is handled, what was filed, what wasn't filed, how inaccurate it was (most if over 25% wrong have yet special rules and penalties) etc. And, almost all SOLs, especially those on income, only start to run once a return is filed....so if you never filed a return, the SOL is essentially forever. AND IF A TAX IS ASSESED BEFORE THE SOL RUNS OUT, IN MOST PLACES, THAT ASSESSMENT NEVER TIMES OUT...THE RIGHT TO COLLECT REMAINS.

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